The petitioner, a Chartered Accountant, filed a Public Interest Litigation under Article 32 of the Constitution seeking directions to the Union of India, the GST Council, and all States to implement a system for electronic (digital) generation of a Document Identification Number (DIN) for all communications issued by State Tax Officers to taxpayers and related persons. It was submitted that such a system would ensure transparency, accountability, and prevent misuse of authority by eliminating undated or unauthorised correspondence. The petitioner relied on the Central Government’s 2019 decision to introduce the DIN system for the Central Board of Direct Taxes (CBDT) and sought similar implementation in the indirect tax administration across all States.

The Supreme Court acknowledged the importance of implementing a DIN system to promote transparency and accountability in tax administration. It observed that while the DIN system had been successfully implemented for direct taxes by the Central Government and adopted by the States of Karnataka and Kerala, other States had not yet introduced it. The Court held that, under Article 279A of the Constitution, the GST Council was empowered to issue advisories and recommendations to States on GST-related matters. Accordingly, the Court directed the Union of India and the GST Council to issue advisory instructions to all States for implementing the electronic DIN system in the indirect tax administration. The Court also directed that a copy of the order be sent to the Chief Secretaries of all States to take appropriate steps for compliance. The writ petition was disposed of with these directions.